Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT held that the reassessment proceedings were jurisdictionally infirm and directed annulment of the resultant assessment. The Tribunal found the AO did not adjudicate the assessee's specific objections and that the purported draft order did not reflect disposal of objections, rendering the proceedings procedurally defective. Consequentially, the assessment order framed under section 147 read with section 144B was set aside and the notice issued under section 148 was quashed. The Tribunal allowed the additional ground raised by the assessee and remitted no matter for fresh exercise of jurisdiction in the absence of valid compliance with mandated objection-disposal procedure.
ITAT held that the reassessment proceedings were jurisdictionally infirm and directed annulment of the resultant assessment. The Tribunal found the AO did not adjudicate the assessee's specific objections and that the purported draft order did not reflect disposal of objections, rendering the proceedings procedurally defective. Consequentially, the assessment order framed under section 147 read with section 144B was set aside and the notice issued under section 148 was quashed. The Tribunal allowed the additional ground raised by the assessee and remitted no matter for fresh exercise of jurisdiction in the absence of valid compliance with mandated objection-disposal procedure.
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